ML20245D459

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Forwards Amended Response to Violation B.2 Noted in Insp Rept 50-344/89-01,per RP Zimmerman
ML20245D459
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 06/22/1989
From: Cockfield D
PORTLAND GENERAL ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8906270119
Download: ML20245D459 (3)


Text

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Portland General ElechicCompany-l I

David W. Cockfield Vice President, Nuclear 1

June 22, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 j

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U.S. Nuclear Regulatory Commission ATTN: ' Document Control Desk Washington DC 20555

Dear Sir:

Amendment to Portland General Electric Compey's

_ PCE) Earlier Reply to a Notice of Violation

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A letter dated May 23, 1989 from Mr. R. P. Zimmerman of Region V requested PCE to amend its earlier response to a Notice of Violation associated with Nuclear Regulatory Commission Inspection Report 50-344/89-01. The amended i

response was required to addrecs the supervisor /manQ;ement contribution to q

Violation B.2 in the Notice of Violation. Attached is our amended response i

to Violation B.2.

One of the actions PGE has trsn to improve the performance of quality control observat4ons is ihn addition of a contract instrumentation and control (I & C) technician the quality control staff.

Changes from the earlier response are shown by's vertical line in the right margin.

Sincerely, j

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\\l g%8 Attachment NotL 40 oo c:

Mr. John B. Martin Mr. William T. Dixon Regional Administrator, Region V State of Oregon i

l U.S. Nuclear Regulatory Commission Department of Energy g-o "oO Mr. R. P. Zimmerman, Acting Director Mr. R. C. Barr

' if Division of Reactor Safety and NRC Resident Inspector-

.o Projects, Region V Trojan Nuclear Plant

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U.S. Nuclear Regulatory Commission l

. o> a.G 121 S W Simon Stect Portarv1 Oregon 97204

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Trojan Nuclear Plant Document Control Desk Docket 50-344 June 22, 1983 License NPF-1 Attachment Page 1 of 2 AMENDED REPLY TO VIOLATION B.2 Violation B.2 Licensee Quality Inspection Procedure QIP 15, **QI observations of I&C Calibration Activities". Revisica 0, approved January 4, 1989, specifies, in part, that the quality coscisl inspector shcIl note whether work was performed in accordance with approved instructions, procedures, and/or technical manuals to assure that plant procedures, work package instruc-tions, and installation standards are followed.

Contrary to the above, on February 2,1989, a quality control inspector failed to note and document failures to follow approved procedures during the performance of channel functional testing of steam generator water level instrumentation per licensee procedure PICT-5-2.

l This is a Severity Level IV violation.(Supplement I).

Amended Reply to Violation B.2 PGE acknowledges the violation.

1.

Reason for the Violation:

a.

The reason for this violation is personnel error. The quality control. inspector failed to recognize the procedural non-compliance because he had not adequately reviewed the PICT-5-2 procedure ahead of time and did not have a copy of the procedure with him while observing the channel functional testing. The inspector was notified of his assignment to perfona the obcerva-tion only a few minutes before the testing was tc begin.

b.

Although management expectations had been conveyed to the quality control inspector, the expectations were not adequately incorpo-rated in the scheduling of PICT observations. Quality control observations of PICTs were not assigned to inspectors far enough in advance to allow them to adequately prepare for the inspec-tion.

This practice was inconsistent with management's expecta-tions of attention to detail, procedural compliance and personal accountability.

2.

Corrective Steps Taken and Results Achieved:

a.

An Instrumentation and Control (I&C) technician has been contracted by the Nuclear Quality Assurance Department to supply added technical knowledge / skills to assist the quality control inspectors to verify compliance to technical elements of PICT procedures. The I&C technician has been assigned t90 specific tasks as follows:

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Trojan Nuclear Plant Document Control Desk Docket 50-344 June 22, 1989 License NPF-1 Attachment i

Page 2 of 2 j

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l (1) provide technical support to quality control inspectors i

while performing PICT observations to better enable the inspector to verify procedure compliance.

j (2) irovide technical training to quality control inspectors on

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why PICTs are performed, how they are performed and the function of the associated circuitry and devices.

b.

Scheduling of PIC2 observations has been improved.

Iespectors I

are now assigned to specific PICT observations in advance to allow adequate preparation time.

c.

To emphasize the need to ensure that the approved procedures are i

followed, management expectations of the role of qual 3ty control l

inspections in verifying procedural compliance were discussed with all inspectors. It was emphasized that verification of z

procedural compliance requires that the inspector be familiar with the procedure and have a copy with him during the observa-tion.

Gelected pICT observations performed by quality cortrol inspectors have been observed by management to ensure that expectations have been implemented. Management found that the observations were performed in compliance with procedures and their expectations.

3.

Corrective Steps That Will be Taken to Avoid Further Violations:

a.

Electrical quality control inspectors will participate in the classroom training sessions of the I&C technician quarterly training program to improve the inspectors' knowledge of I&C activities. Participation in this training is scheduled to begin in September 1989.

h.

All electrical quality control inspectors will attend formal observation training by August 1, 1989.

4.

Date When Full Compliance'Wi1J be Achieved:

Full compliance has been achieved.

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